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VFC Vaccine Provider Enrollment Q&A

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Note: Consult the VFC Operations Guide for questions not answered on this page.

Questions and Answers

Q: What should we do if a VFC-enrolled primary care provider does not want to order or offer one specific VFC vaccine based on his or her medical judgment?

A: The VFC statue, at section 1928(c)(2)(B)(i) of the Social Security Act (42 U.S.C. 1396s(c)(2)(B)(i)), states within the provider agreement section that the provider agrees as follows:

"Subject to clause (ii) the provider will comply with the schedule, regarding the appropriate periodicity, dosage, and contraindications applicable to pediatric vaccines, that is established and periodically reviewed and, as appropriate, revised by the…[ACIP], except in such cases as, in the provider’s medical judgment subject to accepted medical practice, such compliance is medically inappropriate." CDC interprets this provision to mean a medical judgment based on the situation of an individual VFC patient. Except as noted in the next Q and A regarding varicella vaccine, only specialty providers may choose, at the discretion of the awardee, to offer only specific VFC vaccines and their choice is based on the scope of their medical practices. Other VFC providers must offer the full list of VFC vaccines according to the schedule determined by the ACIP in its VFC resolutions, except when in the provider’s medical judgment, subject to accepted medical practice, the circumstances of an individual VFC patient makes such vaccination medically inappropriate.

Q: Our state has large rural areas and many rural providers do not have the appropriate storage units to stock varicella vaccine and may be the only medical provider for several hundred miles. Are these providers non-compliant with the provider agreement for the VFC program because they are not offering a specific VFC vaccine?

A: Certain vaccines, such as varicella vaccine, require special storage and it would be accepted medical practice not to order or store those vaccines if the provider did not have the appropriate storage facilities. We encourage grantees to assist providers in finding ways to obtain vaccine storage that will allow provision of all VFC vaccines.

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Q: When enrolling inpatient facilities such as birthing hospitals or juvenile inpatient treatment facilities in the VFC program, is it necessary to list all providers (e.g., residents, interns) authorized to administer vaccines under the supervision of the VFC provider who signs the enrollment form?

Q&A updated July 2011

A: No. Due to the potentially large number of individuals that would be listed on the form and the difficulty in maintaining the accuracy of the list, it is not necessary to list these individuals on the enrollment form for birthing hospitals.

Q: Can a pharmacist become a VFC program registered provider?

Q&A updated July 2011

A: Yes, in accordance with state law. If a pharmacist is granted the authority to administer vaccine by state law (whether by prescription, protocol, or prescribing authority), the pharmacist is eligible to become a VFC program registered provider within the state.

In jurisdictions where pharmacists are not authorized to administer vaccines except under the direct supervision of a physician, then the supervising physician must co-sign the provider enrollment agreement along with the pharmacist in order for the pharmacist to be enrolled as a VFC registered provider.

Q: Must specialty providers offer all age-appropriate VFC vaccines to their VFC-eligible patients in order to enroll in the VFC program?

Q&A updated July 2011

A: No. Specialty providers enrolled in the VFC program, at the discretion of the awardee, may limit their VFC practice to particular relevant vaccines. Specialty providers would include birthing hospitals, juvenile detention centers or juvenile inpatient treatment facilities, OB/GYN practices, family planning and STD clinics, and pharmacists/ pharmacies.

 

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